Circadian Trust Privacy Notice

CIRCADIAN TRUST PRIVACY NOTICE  (V9. 27.01.2020)

This privacy notice sets out how Circadian Trust uses and protects any information that you provide. This notice may occasionally be updated; you should check this page from time to time to ensure that you are happy with any changes.

For the purpose of the General Data Protection Regulations (GDPR) and the Data Protection Act 2018 (DPA2018), our Head Office contact details are Circadian Trust, Head Office, Thornbury Leisure Centre, Alveston Way, Thornbury, South Gloucestershire BS35 3JB. Contact email: leisure@circadiantrust.org

Who are we?

Circadian Trust operates Active Lifestyle Centres based in South Gloucestershire.

What information do we collect from you?

We take your privacy seriously and your information will always be handled confidentially.

Circadian Trust may collect the following information:

• Personal details such as name, age, occupation, ethnicity* and any disability*.
• Contact information including residential address, email and phone number.• Physical activity levels, body composition measurements and medical conditions provided in person or through third party applications you have consented to use.
• Information such as your preferences, activities and interests.
• Financial details when a single transaction has taken place or when taking out any pre-paid or direct-debit membership.
• Other information relevant to customer surveys and feedback.

* If provided to us, this information is used to ensure we are meeting our obligations to offer leisure facilities that represent the needs of the local community, and is also a requirement of our partnership with South Gloucestershire Council.

How do we collect your information?

When you use our services, for example swim in one of our pools or attend a class, we collect data to make these services work for you. Data can be collected in the following ways:

• Registering for an Active Card.
• Joining as a pre-paid Active Member.
• Taking part in an activity or when using the cafes at Active Lifestyle Centres.
• When submitting your details on a website form.
• Enquiring about services in person, by phone, website or email.
• Registering to use 3rd party applications such as MyWellness Cloud, HomePortal, SwimTag and RB Digital.
• Registering or booking a Lifestyle trial.
• When you have consented to take part in our Active Lifestyle GP Referral Programme.
• Filling in a paper-based or digital form.
• Completing a paper-based, face-to-face, telephone, or electronic survey.
• Participating in a competition, event or a promotion sponsored by us.
• Clicking onto an advert, email, or text
• CCTV located within our Centres and Car Parks
• Sharing your location and device information.

How we use your information

We use your personal information to administer and deliver services relevant to your membership contract, such as inform you of bookings and purchases. We will also notify you of services, products and any other information linked to your membership.

We also hold information on people who have been banned from using our facilities and premises.

We use CCTV at several locations for Health & Safety monitoring and your security. It is used in some swimming pools to help detect individuals struggling or drowning in the water.  CCTV footage maybe shared with the Police or other statutory bodies in the event of an incident.

The information we collect from you is held on our internal leisure data management system. Under the Active partnership agreement, where you consent to share information with South Gloucestershire Libraries, your personal data will be used by Active South Gloucestershire Libraries and library partners in the LibrariesWest Consortium.

Circadian Trust only share your data with third parties who process data related to the administration of your membership on our behalf e.g. the processing of your direct debit or internal reporting systems. We only use GDPR and DPA2018 compliant companies.

Should you contact us with a comment or request for information about our services we will only use your details for this matter and will not contact you for any other purpose unless you have given us consent to do so.

Provided we have been given your consent, we may also use your information to contact you for market research purposes, contacting you by your preferred method of communication. We may use the information to improve our facilities and services.

How secure is my information?

Your information will always be handled confidentially and we will not sell, distribute or lease your personal information to third parties, unless we have your permission, or are required by law to do so. We will only share your data with the Active Partnership where we have a data sharing agreement in place.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. We are committed to handling data in accordance with the data protection principles under the General Data Protection Regulations and the DPA2018.

Active Lifestyle GP Referral Programme

Participants:
Your information is confidential and will not be used for any other purpose than the GP Referral Programme. When you attend GP Referral Sessions, our Active Healthy Lifestyle Specialist will record information about your physical and mental wellbeing, as well as biometric measurements, in order to measure and report on your progress. Your information is stored securely, on a password protected, online patient referral system which is only accessible by Active Healthy Lifestyle Specialists and your GP Practice. Your information will only be used by Active Healthy Lifestyle Specialists and your GP to monitor your progress, and in order to report on the success of the GP Referral Programme through anonymised data reporting. You can apply for access to your information by writing to Circadian Trust, Head Office, Thornbury Leisure Centre, Alveston Way, Thornbury, South Gloucestershire BS35 3JB. Contact email: leisure@circadiantrust.org You do not need to provide a reason.

Younger customers

At the age of 13 years, we will continue to hold a young person’s data on our system for the purpose of delivering services to them (e.g. swimming lessons). We will not contact the young person directly with services or products related to their membership unless they have specifically requested for us to do so.

How long do we retain your information?

If a membership containing personal data has become inactive, it will be kept for no longer than 3 years unless it is necessary for auditing purposes or is relevant to an accident and/or claim. When personal information has been retained in relation to an accident or claim by an adult, Circadian Trust will retain your information for a minimum of 3 years. Information relating to accidents to minors (under the age of 18 years) will be kept until the minor has reached the age of 21 years.

CCTV images are kept for a minimum of 31 days. In the event of an incident, we may retain it until any investigations are concluded.

Poolview CCTV (used in the swimming pools) is kept for 7 days.  In the event of an incident, we may retain it until any investigations are concluded.

How can I change my personal information?

You may choose to restrict the collection or use of your personal information in the following way:

Contact preferences:
If you wish to change how you are contacted or wish to receive no contact from us regarding your membership, you can inform us by writing to leisure@circadiantrust.org

Incorrect or Incomplete Details:
If you believe that any information we are holding on you is incorrect or incomplete, please either: email, write or speak to a member of Customer Services at your nearest Active Lifestyle Centre (www.activecentres.org/centres)

How can I erase my details?

You can request to erase your details at any time in person, by email (leisure@circadiantrust.org), or by post. There may be circumstances in which Circadian Trust can refuse requests to erase your details, for example, if your membership contract has yet to expire, you owe an outstanding sum of money, for medical or legal reasons, or if you have been banned from using our facilities and premises.

How can I access the information you hold about me?

You may request details of personal information which we hold about you under the General Data Protection Regulations and the DPA2018. If you would like a copy of the information held on you please write to:

Active Lifestyle Centres:
Administration, Head Office, Circadian Trust, Thornbury Leisure Centre, Alveston Hill, Thornbury, BS35 3JB.

Use of our Website

Information about www.activecentres.org cookies and its online and transaction tools.

What information do we collect?
We may collect, and use the following types of information:

• Information that you have provided to us for the purposes of purchasing a product, or registering for a service.
• Information relating to any transactions through www.activecentres.org
• Information relating to online enquiries.
• Information that you provide for the purpose of applying for an online trial pass or when subscribing to our newsletters.
• Information about your device, your online visits and how you use our website e.g. referral source, length of visit, page views, website navigation. This includes your geographical location, device type, and browser type.
• Any other information that you submit to us.

Cookies

We use cookies on our website www.activecentres.org to help provide our online visitors with an easy, reliable, faster, and safe service.

Cookies are small files which are placed on your computer, tablet or mobile phone, as you browse through websites. We use cookies to discover how our website visitors are using our online services and to look at how to make these work better. Cookies cannot be used to identify you personally. You can control cookies through the settings on your web browser.

Here are a few examples of some of the ways we use cookies to improve the online services we provide:

• We enable a service to recognise your device so you don’t need to submit the same information several times.
• Our site recognises that you may already have set up an account username and password so you don’t need to repeat the task.
• We measure how many people are using our services, so we can improve services.

What Cookies do we use?

The cookies listed below are examples of cookies served through the website hosted on the activecentres.org domain:

Report a concern

If you experience problems with how your information is handled, please contact  Circadian Trust, Head Office, Thornbury Leisure Centre, Alveston Way, Thornbury, South Gloucestershire BS35 3JB

Should you have a concern about our practices, you can report it to the ICO (Information Commissioners Office) by calling 0303 123 1113 or by visiting www.ico.org.uk/concerns